- 49 -
2001) (“The Internal Revenue Service is a ‘department or agency’
of the United States.”).
In Malone v. Commissioner, T.C. Memo. 1998-372, we imposed
sanctions totaling $15,000 against the taxpayers for advancing
frivolous arguments, including the argument that the Internal
Revenue Service is not an agency of the United States: “Contrary
to petitioners’ argument, there is, in fact and in law, an IRS.”
In Brandt v. Commissioner, T.C. Memo. 1993-411, we imposed
section 6673 sanctions of $5,000 for meritless arguments
disputing the Internal Revenue Service’s authority. Petitioner
cited none of these authorities to the Court.
Furthermore, the authorities petitioner cited do not support
his argument. The issue in Chrysler Corp. v. Brown, 441 U.S. 281
(1979), was whether Chrysler could maintain an action to enjoin
the Secretary of Labor from making public reports that Chrysler,
as a Government contractor, was required to file to show
compliance with Federal affirmative action guidelines. One of
the issues considered by the Court was whether disclosure was
prohibited by the Trade Secrets Act, 18 U.S.C. sec. 1905. The
Court noted that the origins of the modern Trade Secrets Act
could be traced to an 1864 act barring Government revenue
officers from making unauthorized disclosure of a taxpayer’s
business information. The Court noted that the 1864 Act was
repealed in 1948. In a footnote, the Court made a historical
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